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Contributions Program 2020-21

Applicant’s Guide

Office of the Privacy Commissioner of Canada


1. Purpose of this Guide

This guide is designed to help applicants prepare a project proposal for funding under the Contributions Program of the Office of the Privacy Commissioner of Canada (OPC). Specific instructions for completing the application form as well as information about the assessment process are provided.

1.1 Eligible Applicants

Only not-for-profit organizations – including consumer, voluntary and advocacy organizations, educational institutions, and industry & trade associations – are eligible for funding.

1.2 Non-Eligible Applicants

  • For profit organizations
  • Political parties and organizations involved in partisan political activity
  • Current or former public office holders or public servants who are not in compliance with the Conflict of Interest Act, the Values and Ethics Code for the Public Service, the Lobbying Act, or any other relevant guidelines, principles or codes relating to conflict of interest or post-employment

1.3 Application Date

The deadline for receipt of applications is January 6, 2020, at 11:59 PM (your local time).

Please forward your application to the following address:

Office of the Privacy Commissioner of Canada
Care of: Contributions Program
30 Victoria Street
Gatineau, Quebec
K1A 1H3
Email: contrib@priv.gc.ca
Fax: 819-994-5424

Note

Applicants should note that all information requested in the Guide, Application Form and Schedule B—Project Budget must be received by the Office before an application is considered complete.

Only complete applications received at the above noted coordinates on or before the Program deadline will be considered.

Important: Applications are deemed to have been received by the Office of the Privacy Commissioner of Canada on the date they are post-marked; the date they are delivered to a messenger or specialized courier agency; or the date they are sent by fax or e-mail. If you do not receive a receipt confirmation for your proposal, it is recommended that you verify with our Office to ensure that delivery of your application has been received by us.

1.4 Contributions Program Budget

The budget for the OPC's Contributions Program is $500,000 annually, all of which we are making available under the present call.

We will award up to $50,000 to any single project and a maximum of $100,000 per recipient organization. In addition, we are reserving $50,000 out of this year’s budget for proposals related to the organization of a “Pathways to Privacy” symposium. See Section 2 below for more information on the symposium and details regarding the theme of this year’s call.

Please note that the Program’s budget is subject to cancellation, reduction or increase in the event that funding levels are changed by Parliament.

2. Contributions Program

2.1 Objectives

The Program’s objectives are to:

1) Strengthen existing privacy research capacity in academic and not-for-profit sectors;

2) Generate new knowledge and support the development of expertise in selected areas of privacy and data protection;

3) Increase awareness and understanding among individuals and organizations across Canada of their privacy rights and obligations; and,

4) Promote uptake and application of research results by relevant stakeholders.

2.2 Eligible Projects

The Contributions Program finds its authority under the Personal Information Protection and Electronic Documents Act (PIPEDA), which governs the collection, use or disclosure of personal information by organizations in the course of commercial activities. Accordingly, only research and/or related knowledge translation proposals that address privacy issues in the private sector will be considered.  Proposals that touch on issues falling within the federal public sector can be submitted, provided that the primary focus of the proposal deals with the private sector.

2.3 This Year’s Call

2.3.1 Innovative Research Related to OPC Strategic Priorities

As in past years, the OPC is calling for any and all research or knowledge translation proposals that relate to one or several of our priority areas and related implementation strategies. The OPC’s priority areas are:

  1. The Economics of Personal Information
  2. Government Surveillance
  3. Reputation and Privacy, and
  4. The Body as Information

In implementing these priorities, the OPC has committed to adopting the following cross-cutting strategies:

  • Exploring innovative and technological ways to protect privacy
  • Strengthening accountability and promoting good privacy governance
  • Protecting privacy in a borderless world
  • Enhancing our public education role
  • Enhancing privacy protection for vulnerable groups.

2.3.2 This Year’s Theme: Artificial Intelligence and Privacy

While we welcome proposals on a wide range of topics, this year the OPC is particularly interested in funding proposals that deal with issues related to the intersection of artificial intelligence (AI) and privacy.

A growing number of thinkers and researchers are pointing out that artificial intelligence, despite all its advantages, poses significant challenges to privacy and data protection. There is no doubt that profound ethical and legal considerations accompany the rapid advance of this technology, warranting further and serious consideration from a privacy perspective. For these reasons, we would like to receive research or knowledge translation proposals that address this complex issue. For instance:

  • How to design AI systems that take into account privacy protection as soon as they are designed . 
  • How can a Privacy Impact Assessment model for AI systems incorporate elements from impact assessments affecting human rights, algorithms, ethics and data?
  • How to design AI systems that prevent discrimination against certain individuals or groups because of inherent bias.
  • How to use the Personal Information Management Systems (PIMS) to allow individuals to better monitor their data in AI systems.
  • What are the creative approaches that allow organizations to be more transparent with individuals regarding their AI practices and the processing of personal data?
  • How to create a legislative or regulatory framework for AI that protects personal data and promotes privacy rights.
  • How to ensure, in the context of personal data protection, algorithmic transparency and accountability in the responsible development of AI applications.
  • Finally, which state of the art techniques that respect privacy, such as the use of synthetic data, differential privacy and depersonalization, are the most effective for organizations to minimize risks to the protection of personal data ? 

2.3.3 Special Call: Pathways to Privacy Symposium

The Office is also issuing this year a call for proposals to organize and host the next research symposium in the Office’s Pathways to Privacy (P2P) series. We are making up to $50,000 available for the organization of the symposium.

The goal of the Pathways to Privacy series is to expand the reach and application of knowledge in the field of privacy, so that more people can benefit from this knowledge. The series also aims to promote and encourage dialogue between the people who conduct privacy research and those who can apply it in the private or public sectors.

The proposed symposium should put a strong emphasis on innovation, in terms of both format and themes. Applicants are encouraged to consider presenting symposia proposals that deal with artificial intelligence and privacy as the event’s main topic, given that this is also the key theme of this year’s overall call for proposals. That said, we welcome and will consider symposium proposals that deal with other cutting-edge, innovative themes, as long as these address one or more of the OPC's privacy priorities. To the extent possible, the content of the symposium should also prominently feature current or previously funded projects under the Contributions Program. 

Eligible organizations must submit proposals in accordance with the established parameters, as outlined in this Guide. Funds may be used only for expenses directly related to the organization and hosting of the symposium. Eligible expenses may include:

  • Salaries and benefits for members of the project team;
  • Administrative costs, translation, secretarial assistance and publication costs;
  • contract costs for expertise not available in-house or work not reasonably performed in-house; and
  • Other costs including travel (not to exceed government travel regulations), materials and supplies, and communications.

2.3.4 Public Education and Knowledge Translation

Funding is also available to eligible organizations to conduct privacy-related, public education and awareness raising initiatives. We especially encourage research applicants to integrate knowledge translation activities as part of their project proposals. Knowledge translation is the process by which theoretical research findings are transformed into outcomes that end-users can apply in practice. Knowledge translation activities may be built into your research proposals, or further build upon past OPC-funded research.

Examples of public education or knowledge translation activities that we would consider funding include:

  • Workshops or conferences aimed at disseminating research results to stakeholders;
  • Innovative and interactive online approaches for disseminating research findings and raising public awareness of privacy issues;
  • Privacy guidelines for parents to use in discussions with children;
  • Education curriculum for teachers to use in teaching students;
  • Content for journalists and specialized media to report on privacy issues impacting Canadians;
  • Toolkits for consumer protection organizations to use in better supporting consumers to make informed, privacy-senstive choices;
  • Privacy best practices for professional associations to promote among their members;
  • Educational games, videos, and documentaries aimed at general and public audiences.

We welcome all creative public education and knowledge translation proposals aimed at achieving the objectives of the Contributions Program, as set out in section 2.1 above and other sections of this Guide.

2.4 Encouraging Partnerships Between Academia and Civil Society

The Program has made substantial gains over the past years in funding a greater diversity of research applicants. The Office wishes to continue to engage actively civil society groups through the Program, so that by way of these groups increased public awareness of research findings generated under the Program may be achieved.

To this end, the Office this year again encourages universities and other research groups to develop new partnerships with civil society organizations as part of their proposals. For example, universities could collaborate with public education groups, or advocacy associations could partner with research groups. Additional points during the assessment process will be allocated to proposals that put forward plans for such partnerships.

2.5 Work Previously Done Under the Program

The Contributions Program seeks to advance the creation and translation of new knowledge on emerging issues related to privacy promotion and protection. Accordingly, applicants are encouraged to take into account previous projects completed or currently being completed under the Contributions Program when developing their proposals. A full list of Contributions Program-funded projects completed since the Program’s inception in 2004 is available on our website, as well as a list of the projects currently under way as a result of last year’s call and which will be completed in March 2020.

2.6 Projects must be National in Scope

The mandate of the OPC is to oversee compliance with the Personal Information Protection and Electronic Documents Act, Canada’s national, private sector privacy law. Accordingly, only projects that are nationwide in scope and/or application, and are relevant to the federal government’s sphere of jurisdiction will be considered for funding. Projects that examine issues or address concerns that are exclusively or predominantly local, provincial or foreign in scope will not be considered for funding.

2.7 Projects Must Include Detailed Methodology

The proposals that are submitted under the Contributions Program can be qualitative and/or quantitative in nature. In both instances, the OPC seeks to fund proposals that demonstrate sound methodology. In order for the OPC to evaluate a proposal’s methodology, the applicant must provide a detailed description of the means by which they seek to achieve their results. Where applicable, applicants should provide a detailed list of stakeholders they intend to survey/interview and the survey method and instruments they intend to use.

2.8 Duration of Projects

The OPC Contributions Program is structured to provide funding for eligible expenses that are incurred within the same fiscal year that funds have been awarded—that is between April 1, 2020 and March 31, 2021. Incurred expenses must have been paid by the Recipient before they are invoiced to the OPC. Exceptionally, the OPC may fund projects that extend beyond the end of a fiscal year (i.e. March 31, 2021) if the proposal persuasively demonstrates why the project requires more time to be completed and should be funded beyond the typical one-year period. For multi-year proposals, applicants are requested to submit work plans that cover the entire duration of the project.

2.9 Funding Amount Available and Allowable Expenses

As indicated in section 1.4, the maximum budget for the present call is $500,000.

  • Research or knowledge translation proposals: We are making up to $450,000 available for research or public education/knowledge translation proposals. The maximum amount that applicants may request and that can be awarded to a single research or public education/knowledge translation project is $50,000.
  • Pathways to Privacy Symposium: We are making up to $50,000 available for the symposium.

The maximum amount that can be allocated to any single recipient organization is $100,000.

Funds may be used only for expenses directly related to the activities of the project. These activities must be reflected either in the original budgetary submission, or via subsequent approved budgetary adjustments. Eligible expenses would include:

  • Salary and benefits for members of the project team, inclusive of project administrators, researchers and research assistants, students, postdoctoral fellows, technical support, etc.;
  • Administrative costs, translation, secretarial assistance and publication costs;
  • Contract costs for expertise not available in-house or work not reasonably performed in-house (for example surveys); and
  • Other costs including travel (not to exceed government travel regulations), workshops, materials and supplies, and communications.

The OPC will not support any expenses incurred prior to, or after completion of, the funding period stipulated in a Contribution Agreement. The OPC will not support any expenses that have not been paid by the Recipient before they are invoiced to the OPC.

Other ineligible expenses that will not be funded under the Agreement include the purchase of buildings, land, vehicles and most other major capital costs.

Indirect administrative expenses (i.e. overhead) should be limited to no more than 15 per cent of the total project expenses incurred under the Contribution Agreement.

Contributions awarded to an applicant are subject to the terms of the Contribution Agreement signed by the applicant and the OPC. Funds must be spent only on the project and cannot under any circumstances be diverted to any other use. Expenses associated with the project are subject to audit.

For full details, see the Costing Memorandum in Schedule B – Project budget.

3. Completing the Application

The following information corresponds to each section of the Application form. Applicants should provide answers to all questions and include any required detailed information in an appendix to the application form.

3.1 Identification of Applicant

  • Provide the full name of your organization along with any abbreviations frequently used, as well as the section name or division name;
  • Previous name, if changed in the last year;
  • Address, telephone numbers (with extension), fax numbers, e-mail addresses, and web site addresses, where applicable.

The mailing address and billing address should include full information on the organization's location, such as floor, suite or room number, street number and postal code. Should a Post Office Box be designated as the official mailing address, please provide this information as well.

3.2 The Proposal

Applicants must provide a project proposal which, once agreed to by the OPC, will serve as a basis for the Contribution Agreement and cash flow. The project proposal should contain:

  • Basic Information: Organization name, address, billing address, telephone number, facsimile number and e-mail address of the applicant's authorized representative, , names of principal personnel and project administrators. Please provide contact information for the principal researcher (where applicable), the person responsible for administering the project, and the finance/accounting contact person.
  • Legal Status: An attestation/confirmation that your organization is a not-for-profit organization.
  • Organizational Background: Background of the organization including its mandate, objectives, and accomplishments.
  • Previous Financial Support: An indication of any previous financial support received in the last five years from the OPC including the amount, the year when the funding was provided, the purpose of the funded activity, and the results achieved.
  • Project Description: A detailed project description including project title, goals and objectives, identification of the target groups for the proposed project, identification of the anticipated results and expected benefits for Canadians in terms of the creation and application of new knowledge in the area of privacy and data protection. A listing of project deliverables must also be provided.
  • One-Page Summary: A concise one-page summary of the proposed project that can be used for the Contribution Agreement.
  • Timeline and Monitoring: Timeframe, work plan detailing activities to be undertaken to support the attainment of project objectives, and monitoring activities.
  • Budget: A detailed budget for the project showing amount(s) being requested from the OPC and other proposed sources of revenue, including in-kind support. In presenting the budget to the OPC, Applicants must use the form provided with this Guide, namely Schedule B — Project budget. Furthermore, in their proposal, Applicants must provide detailed information explaining and justifying each amount entered in Schedule B — namely for salaries and benefits; travel expenses; telecommunications; contractual services; materials and supplies; rentals (includes equipment and meeting rooms); and other expenses.
  • Community, Sectoral, or Industry Involvement: Where appropriate, an indication of the level of community, sectoral or industry involvement (commitment, endorsement, scope and level of participation, co-operation and volunteer involvement).
  • Provincial/Territorial Support: Where appropriate, an indication of the degree of provincial, territorial and municipal support for the project (cash and/or in-kind).
  • Knowledge Translation Activities: A plan for disseminating project results and enabling their uptake and application by relevant end-users (e.g. targeted stakeholders, organizations, industry associations, individuals, consumers, communities, educators, journalists, and/or the general public).
  • Acknowledgement of OPC Funding: An indication of how the project will acknowledge the financial support (and where relevant, other contributions) of the Office of the Privacy Commissioner of Canada to the project.

3.3 Declarations

Applicants are required to answer the questions in the Application form regarding the Conflict of Interest Act, the Values and Ethics Code for the Public Service, and the Lobbying Act.

3.4 Other Sources of Funding

Applicants may seek other sources of funding for proposed projects. Applicants are required to disclose all sources of funding for a proposed project when applying for funding from the OPC. This includes financial assistance (grants, contributions, etc.) from all levels of government, anticipated or received, that is related to the proposed project. This should also include applications for financial assistance which are still pending.

In the event that total government assistance (including provincial and municipal assistance) received for the project exceeds the cost of the project, the Recipient will repay Her Majesty the Queen in Right of Canada on a pro-rated basis (based on the OPC's share of total government assistance received).

4. The Assessment Process

4.1 Assessments Based on Merit

Each request for financial support will be reviewed to determine the quality, relevance and timeliness, feasibility and expected outcomes/benefits of the proposed project. Applicant organizations and applications for funding will be reviewed in accordance with the general Program objectives as well as the specific eligibility criteria as outlined in this Guide.

In assessing proposals, the OPC may, where appropriate, consult with other federal departments, provincial and territorial governments and other privacy commissioners or ombudsmen. The OPC may also involve independent, external reviewers from academia or the not-for-profit sector.

4.2 Screening Criteria

In order to proceed to full assessment, all proposals submitted to us must, in addition to meeting the eligibility criteria in section 1.1, also meet these two (2) screening criteria:

  1. OPC priorities and strategic approaches – Only proposals that align with at least one of the OPC’s priorities will be considered. The OPC’s priorities are: the Economics of Personal Information; Government Surveillance; Reputation and Privacy; the Body as Information. (See section 2.2 above for more information.)
  2. PIPEDA – Only proposals that address privacy issues relevant to the Personal Information Protection and Electronic Documents Act (PIPEDA) will be considered. Proposals that touch on issues that fall within the federal public sector can be submitted, provided that the primary focus of the proposal deals with the private sector or the interface between the private and public sectors. (See section 2.2 above for more information.)

Projects that are screened in based on the above-mentioned conditions will then be evaluated on the basis of the following assessment criteria:

4.3 Assessment Criteria

General Quality and Competencies (25 points)

  1. Overall quality (10 points)
  2. Knowledge and understanding of relevant privacy issues (5 points)
  3. Integration of interdisciplinary perspectives and approaches (5 points)
  4. Relevant partnerships and collaborations (5 points)

Innovation (30 points)

  1. Novelty of issue(s) being examined or solution(s) being proposed (15 points)
  2. Creativity of methodological and/or knowledge translation approach (15 points)

Feasibility (15 points)

  1. Realistic budget (5 points)
  2. Soundness of proposal (5 points):
    1. Sound methodology for research or knowledge translation proposals
    2. Sound planning for the Pathways to Privacy symposium proposals
  3. Manageable scope and timelines (5 points)

Expected Benefits and Outcomes (30 points)

  1. Expected positive impact on Canadians’ privacy rights (10 points)
  2. Effectiveness of knowledge translation strategy (10 points)
  3. Relevance and timeliness of expected outcomes (10 points)

4.4 Past Instances of Non-Compliance

The OPC may choose to not assess or fund projects from applicants who, as past funding recipients of our Program, have been in default of their contribution agreements. This includes but is not limited to instances where applicants who were past Program recipients were late in submitting their deliverables, submitted incomplete or unsatisfactory deliverables, or were derelict in posting their projects to the Internet.

5. Reconsideration Process

The OPC is committed to the integrity of its merit review process. Reconsideration of negative funding decisions may be requested only by the applicant named in the application. Applicants may seek reconsideration of a funding decision only where evidence suggests that a palpable error occurred during the merit review process and that this error resulted in a negative funding decision for their application.

5.1 Eligible Requests for Reconsideration

Palpable errors are marked departures from the policies and procedures set out in this Guide, and without limiting the generality of the foregoing may include:

  • A failure by OPC staff to provide required information to the reviewers of the proposal;
  • A decision not to recommend funding based on a conclusion that is contrary to information provided by the applicant in the proposal.

The OPC will not reconsider funding decisions based solely on:

  • differences of opinion pertaining to eligibility;
  • differences of opinion based on the merits – i.e. the relative strengths or weaknesses –  of a proposal;
  • disagreement over the interpretation or analysis of the proposal;
  • the qualifications or number of reviewers who assessed the proposal;
  • the amount awarded.

5.2 Procedures

Applicants seeking further information about the review of their application are encouraged to communicate with the OPC Contributions Program at contrib@priv.gc.ca as a first point of contact. If, after the initial discussion with Program staff, the applicant still wishes to request formal reconsideration and has the necessary evidence of a palpable error as outlined above, the applicant can submit a formal request to the OPC via email to the address above.

The request should be based on a compelling demonstration that a palpable error occurred in the review process. The OPC will not consider requests for de novo reassessment of the merits of a proposal.

Request for reconsideration must be emailed no later than 60 days after the date of transmission of the funding decision by the OPC to the applicant. Supporting documents not included in the original application may not be submitted with the reconsideration.

In keeping with the principles of merit review, the OPC reconsideration process will seek to involve individuals who were not involved in the original management or review of the application.

The OPC will advise appellants of results by email. Decisions on reconsiderations are final.

6. Control Procedures

6.1 Contribution Agreement

On approval of a request for a Contribution, a detailed Contribution Agreement will be drawn up and signed by the Recipient and the OPC. A Contribution Agreement is an agreement between the Recipient and the OPC regarding the amount of Contribution awarded, in consideration for specific deliverables to be completed.

By accepting a Contribution, the Recipient agrees to carry out the funded project, to be responsible for realizing all deliverables specified in the Contribution Agreement, and to be accountable for the amounts received. As consideration, the OPC agrees, subject to conditions stipulated in the Contribution Agreement and to renewal of the Program by the Minister, to fund all or part of the project's costs.

Important – As specified in the Agreement, the Recipient cannot make material changes to the scope of a project—e.g. significantly changing or dropping a deliverable, or reallocating significant amounts of money from a budget line item to another—without the prior written consent of the OPC.

6.2 Reporting Requirements

By signing the Agreement, the Recipient agrees to submit progress and financial reports, as specified in the Agreement for the duration of the project.

The OPC reserves the right to publish the name of the Recipient, a summary of the project, as well as the amount of the Contribution awarded in any manner it deems fit including, but not limited to, posting on the OPC's web site, publication in the Main Estimates, and so forth.

Recipients of OPC funding under the Contributions Program may also be surveyed after the completion of the project about further related work or follow up activities in an ongoing effort to evaluate the impact of the research and the value of the Contributions Program.

6.3 Research Ethics and Integrity

Where applicable, applicants are required to adhere to the principles and responsibilities of researchers as set out in the Tri-Agency Framework: Responsible Conduct of Research, and if their proposed project involves human participation, the 2nd Edition of the Tri-Council Policy Statement:Ethical Conduct for Research Involving Humans.

6.4 Method of Payment

Payment will be made in accordance with the approved cash flow in the Contribution Agreement, as well as the work plan and the agreed-to deliverables, and will be consistent with Treasury Board guidelines for cash payment under the Policy on Transfer Payments.

Final payment of a hold back, not exceeding 20 per cent of the total Contribution, or recovery of surplus, if necessary, will be made when the Recipient has satisfied all the requirements of the project and upon receipt and acceptance by the OPC of financial statements.

Payments will be made on the basis of documented claims for reasonable eligible costs incurred and paid, to be submitted by Recipients as per the Agreement. The Privacy Commissioner is unable to make any payment to Recipients prior to receiving an invoice for eligible costs that have been incurred.

Payment will be processed using a direct deposit to the Recipient’s bank account, and the Recipient will be asked to provide banking information to the OPC for deposit purposes.

Contributions are normally awarded for specific projects on an annual basis. In the case of projects extending over more than one fiscal year (April 1 to March 31), payment is subject to the appropriation of funds by Parliament, and satisfaction of review and reporting requirements by the Recipient, in accordance with the terms and conditions of the Contribution Agreement.

6.5 Public Acknowledgement and Recognition

The Recipient shall acknowledge the Privacy Commissioner of Canada's Contribution to the project in all materials, be they written, oral or electronic, used to describe the project or resulting from the project. The Privacy Commissioner, or a designated representative of his Office, will be given the opportunity to participate in public announcements related to the project.

6.6 Audit Requirements

In accordance with its Contribution Agreement, the Recipient shall keep proper accounts and records of revenues and expenses received in connection with the funded project, for at least six years after completion of the project. Such accounts and records shall be open to audit and inspection by the OPC to ensure compliance with the terms of the Contribution Agreement. The OPC may make copies and take extracts at all reasonable times for a period of six years after completion of the project.

The OPC may request at any time that Recipients provide satisfactory evidence to demonstrate that all eligible costs claimed have been paid.

6.7 Contribution Payments

Where for any reason:

  • a Recipient is not entitled to the Contribution,
  • the amount of the Contribution exceeds the amount actually expended,
  • a Recipient is late in submitting a deliverable as per the terms of the Contribution Agreement,
  • a Recipient fails to submit one or more deliverables as per the terms of the Agreement,
  • a Recipient submits deliverables that are incomplete or unsatisfactory in relation to the terms of the Contribution Agreement,
  • a Recipient does not provide in his deliverable(s) appropriate value for money, as assessed by the Commissioner in evaluating the quality of the deliverables submitted to him,

the Commissioner may, at his discretion, withhold payment or a portion of the total amount awarded to the Recipient for the project, or require the Recipient to repay all or part of the advances or interim payments to the Office, those amounts being a debt due to Her Majesty the Queen in Right of Canada.

7. Language Policy

Project deliverables may be produced and/or submitted in the Official Language of the Recipient’s choice. Organizations working at the national level and receiving financial assistance from the OPC are encouraged to provide services in both English and French and to foster the recognition and use of those languages especially in areas of significant demand recognized by the Office.

8. Gender-Based Analysis+

In preparing proposals, the OPC asks that applicants give consideration to Gender-Based Analysis+ (GBA+) to ensure that their projects reflect impacts on Canada’s diverse populations and demographics. For more information on the federal government’s GBA+ policy go to the Status of Women Canada website.

9. Access to Information and Privacy

The information provided to the OPC as part of the application is subject to the Privacy Act and the Access to Information Act. For more information about what this entails please contact the OPC’s Chief Privacy Officer at (819) 994-5970.

10. Appendices

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